Product Updates August 2025
The Product Updates for August 2025 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
The update to this product is in response to FinCEN’s “Exemptive Relief Order to Delay the Effective Date of the Investment Adviser Rule” dated 08/05/25 that grants exemptive relief to covered investment advisers from the requirements of the regulation titled Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule). The IA AML Rule is set to become effective January 1, 2026. This order exempts covered investment advisers from all requirements of the IA AML Rule until January 1, 2028. FinCEN intends to issue a notice of proposed rulemaking (NPRM) to propose a new effective date for the IA AML Rule no earlier than January 1, 2028.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to FinCEN Notice FIN-2025-NTC1 entitled “FinCEN Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity” dated 08/04/25 that urges financial institutions to be vigilant in identifying and reporting suspicious activity involving convertible virtual currency (CVC) kiosks. CVC kiosks (also called cryptocurrency “crypto” Automated Teller Machines “ATMs”) are ATM-like devices or electronic terminals that allow customers to exchange real (or fiat) currency for virtual currency and vice versa.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
Cryptocurrency Policy Template
The update to this product is in response to the Joint Press Release entitled “Agencies Issue Joint Statement on Risk-Management Considerations for Crypto-Asset Safekeeping” dated 07/15/25 that provides clarity on banks’ engagement in crypto-asset-related activities. The statement highlights for banks potential risk-management considerations related to holding crypto-assets on their customers’ behalf, or crypto-asset safekeeping.
The joint statement discusses existing risk-management principles that apply to crypto-asset safekeeping and reminds banks that provide or are considering providing safekeeping of such assets that they must do so in a safe and sound manner and in compliance with applicable laws, rules, and regulations.
The statement does not create any new supervisory expectations. The agencies continue to explore ways to provide additional clarity with respect to banks’ engagement in crypto-asset-related activities.
Fair Housing Act Policy Template
Model Risk Management Program Policy Template
Other Real Estate Owned Policy Template
The update to these products is in response to:
OCC Bulletin 2025-16 entitled “Fair Lending: Removing References to Disparate Impact” dated 07/14/25 that eliminates the use of disparate impact liability in all contexts. Consistent with EO 14281, the OCC supervisory process for fair lending compliance no longer includes examining for disparate impact liability. Examiners will not request, review, or conclude on or follow-up on matters related to a bank’s disparate impact risk, internal disparate-impact risk analysis, or disparate-impact risk assessment processes or procedures. The OCC’s supervisory processes continue to include regularly conducting fair lending risk assessments, analyzing Home Mortgage Disclosure Act data for possible evidence of disparate treatment, conducting risk-based fair lending examinations, and taking appropriate action if evidence of disparate treatment is found. The OCC expects banks to provide fair access to financial services, treat customers fairly, and comply with all applicable laws, rules, and regulations.
FDIC update to the Consumer Compliance Examination Manual that removes references to disparate impact effective as of August 29, 2025, in the following chapters. Fair Lending Laws and Regulations (IV-1.1) Fair Lending Appendices (IV-2.1) Fair Lending References (IV-4.1) Unfair, Deceptive, and Abusive Practices – Federal Trade Commission Act/Dodd-Franks Act (VII-1.1) To assist readers in identifying the changes, the FDIC is providing a redline document that identifies all changes here. The FDIC plans to continue this practice when making updates to its exam manuals in the future.
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